CRI(ME) Requirement for ME IR Instruction

[Timothy]

As many will know, an oversight was made by EASA, reflected in CAP804, whereby for an IRI to teach on ME aircraft he needed to meet the prerequisites of a CRI(ME), but didn't actually have to hold one.

This oversight has been amended, and the new wording is as follows:

38) In point (a) of FCL.915.IRI, paragraph (2) is replaced by the following:
(2) in the case of applicants of an IRI(A) for multi-engine aeroplanes, meet the requirements of paragraphs FCL.915.CRI(a), FCL.930.CRI and FCL.935;

So now it is clear that an IRI applicant must have a CRI(ME) to teach IR on ME.

However, I qualified as an IRI in the period when a CRI(ME) was not required and I do not have one.

I believe from the above that my rights to teach on ME are grandfathered and that I do not have to go and do a CRI(ME). Is that what others would agree? Should I get a definitive policy statement from the CAA? In which case who should I write to?

(I do not need a lecture on the good sense of having the CRI(ME). I have done the training electively with an independent, highly qualified instructor. This is only about legality and privileges, not wisdom.)

[S-Works]

Timothy, are you trying to circumvent the policy statement you were already given from the Head of Policy clearly stating that Grandfather rights did not apply and you needed to do a minimum of a CRI on the class that you wish to teach on?

This means that if you want to teach on SE and ME you must hold a CRI for both classes or an FI which includes ME privileges.

But if you want to write to the man who makes the policy again you have the address.

If you are going down the route of soliciting opinions you should probably post the whole story including the policy statement issued to you?

[Timothy]

The eMail from ***** said:

To elaborate further on my reply, this is what I have been told. The law will change between April and July next year to mean that the privileges of an IRI certificate used on SEP or MEP are only valid if the IRI holder also holds an instructor certificate that entitles him/her to give instruction for the Class rating. You can continue to instruct for ME IR privileges now (without holding class rating instructing privileges), but this is an error which is being corrected because it is agreed by both regulators and industry that it is a safety risk. The corrective change to the rule has been voted through by the EASA Committee and will come into force. Therefore IRI certificate holders who intend to teach for ME IR privileges should plan to obtain the relevant ME instructor rating as soon as is practicable - and it is strongly recommended that they do not deliver ME IR training until they do. They will not be able to continue into the future unless they do.

But he says "this is what I have been told" whereas the wording is different.

Maybe best if I just write back to ****, but I was just wondering if there was any knowledge or previous experience of this question being asked on here.

I am not trying to circumvent anything, and do wonder why you are so aggressive on this subject. It is as if you have a personal crusade to fight to get me and others to spend thousands of pounds. Why do you have a hat in the ring?

[Whopity]

I qualified as an IRI in the period when a CRI(ME) was not required and I do not have one. It was a JAR-FCL requirement from July 1999! I doubt that you would be grandfathered on anything obtained prior to that especially as the IRI and CRI were not even invented then.

[Timothy]

I gained the qualification under EASA at the time when CAP804 did not make CRI(ME) a prerequisite, a position which still stands, incidentally.

Thus I have the qualification today to teach on ME. The new CAP804 only applies more stringent restrictions on applicants for IRIs and does not speak to qualifications of existing holders, so it would seem that there is no change.

[Whopity]

CAP804 has no legal status so if it was not an EASA requirement then it would seem there is little they can do retrospectively!

[S-Works]

I am not trying to circumvent anything, and do wonder why you are so aggressive on this subject. It is as if you have a personal crusade to fight to get me and others to spend thousands of pounds. Why do you have a hat in the ring?

I am not being aggressive at all, you know me well enough to not make that accusation. i also have no hat in the ring. When we asked for a policy statement, what came back was not ambiguous to me in any form and was what I had always believed from reading Part FCL. As Whoppity says CAP804 is a guide not the law.

You gained your rating under EASA and as such there is no grandfather rights. You have been told all your teaching is valid and that you now have to gain a minimum of a CRI rating on the class you wish to teach.

Even a man of your experience has something to learn and the CRI will give you the fundamentals of teaching for the Class rather than the IRI that concentrates only on the IR aspects.

Believe me when I tell you that I have been teaching and examining multi engine long enough that it will be worth it to you when a student does something stupid. it will also allow you to do the asymmetric work that is required if you do a CRI(ME).

[Timothy]

I made the point earlier that I have done the training electively, so that is not the matter under discussion.

I have no wish to teach for the ME Class Rating, only to be valid on IR ME, so formally going through a CRI(ME) course and test would be wasteful and time consuming.

Anyway, I have written to ****, I'll see what he says.

[S-Works]

I made the point earlier that I have done the training electively, so that is not the matter under discussion.

Clearly it is. If you have done the training then get it signed off and the problem is then resolved.

[Timothy]

No. To do the full CRI(ME) course at an ATO is a week out of my life, involves either renting an aircraft or getting my aircraft on the ATO books (a big paperwork exercise in its own right), doing ground training, particularly in briefing for things I have no desire to teach, and a Skills Test with a CAA examiner.

Total, including travel and hotel bills, about £4000 plus whatever is the opportunity cost of being away for a week, maybe another £3000.

Instead, I have been to an independent instructor (who is himself a CAA examiner and one of the most experienced people around) and he has taught me, on my own aircraft, what I need to know specifically for IR training on ME types. Total cost, maybe £700.

You can see the difference and why it is worth pushing back if there is no legal requirement?

[Charlie Foxtrot India]

Timothy, please do not publish private messages and emails or "out" people here.

[ifitaintboeing]

The wording of IRI in Part-FCL was an oversight which is being corrected. Under JAR-FCL the requirement was that you had to hold a current CRI/ME and IRI to teach for the MEP-IR. A stand alone IRI could only teach single-engine unless they also hold/held a CRI/ME or equivalent (FI with MEP privileges).

As such, there are no grandfather privileges since it was previously not permitted (under JAR-FCL or UK legislation). I understand that the privilege of the IRI is shortly to be amended to correct an error in EASA legislation returning it to the original intent. Once the wording is corrected, your IRI privileges will be reduced to that which they were originally intended until you have completed the CRI/ME course.

ifitaint...

[Whopity]

(2) in the case of applicants of an IRI(A) for multi-engine aeroplanes, meet the requirements of paragraphs FCL.915.CRI(a), FCL.930.CRI and FCL.935; There is no IRA for multi-engine aeroplanes defined in the document! The IRI is not Class or Type specific.
FCL.905.IRI IRI — Privileges and conditions
(a) The privileges of an IRI are to instruct for the issue, revalidation and renewal of an IR on the appropriate aircraft category. Therefore all it need say is what it said in JAR-FCL(b) the issue of an IR(A) multi-engine
aeroplanes, provided that the instructor meets
the requirements of JAR-FCL 1.380(a).The bit that was missed out.
As Part FCL says you need to be both an IRI and a CRI (ME) then that is what you require. As the training can only be conducted at an ATO they will check that you meet this requirement, elective training is not worth anything.
Have you already been conducting training at an ATO? If so, what does their Ops Manual say? If not, you could hardly claim grandfather rights!

[BEagle]

ifitaintboeing wrote:The wording of IRI in Part-FCL was an oversight which is being corrected. Under JAR-FCL the requirement was that you had to hold a current CRI/ME and IRI to teach for the MEP-IR. A stand alone IRI could only teach single-engine unless they also hold/held a CRI/ME or equivalent (FI with MEP privileges).


However, Timothy's e-mail from ***** stated: The law will change between April and July next year to mean that the privileges of an IRI certificate used on SEP or MEP are only valid if the IRI holder also holds an instructor certificate that entitles him/her to give instruction for the Class rating.

The implication in the e-mail being that the CRI requirement will also apply to IRIs conducting training on SEP aeroplanes. I trust that this is a CAA error and that IRI privileges will, in fact, be as stated by ifitaintboeing, restoring the situation which existed under JAR-FCL?

I'm not sure to what 'elective training' refers in this context; the ATO course requirement and Assessment of Competence requirements are quite clear to me.

Given that Timothy obtained his IRI(A) certificate in all good faith, I would hope that the CAA will grant maximum accreditation of elements already completed for the IRI(A) course towards the CRI(ME) certificate, such as the 35 hours of ground training and will require only those airborne elements of the CRI(ME) course which were not already completed during the IRI(A) course.

Whopity, as I'm sure you know (but others may not), a standalone IRI may conduct IMCR/IR(R) training outside an ATO provided that 'a syllabus recognised by the Civil Aviation Authority' is followed.

[Timothy]

As I said before, that opinion was written before the changes to wording were agreed, and I would say that those changes do not support what was written.

So we shouldn't get too worried about the opinion in the meantime. I have written for further clarification, which, I am sure, will be based on the regulations as they are actually agreed.

[S-Works]

Your issue will be around being able to teach towards an IR without holding a CRI as it will be the ops manual that governs the qualifications required. Our ops manual lists the qualification that must be held on order to teach for each of the courses that we offer.

This was included at the request of the CAS when I did the EASA compliant manuals and was the reason that the whole discussion with Timothy kicked off. My ops manuals requires an IRI to hold a minimum of a CRI and according to my flight ops inspector that all the ATOs will have to observe the new regulation.

This means that even if you win your battle and get some sort of grandfather right you will only be able to teach towards the IMC if that is acceptable to the CAA.

[Timothy]

All of the IMCR/IR(R), 30 out of the 40 hours required for a CBM IR and 5 of the 15 for the EIR can be taught independently of an ATO.

[BEagle]

Timothy wrote:All of the IMCR/IR(R), 30 out of the 40 hours required for a CBM IR and 5 of the 15 for the EIR can be taught independently of an ATO.

While that it is true of the IMCR/IR(R) course, the only requirement being that 'a course recognised by the Authority' is followed, the AMC and GM for the EIR and C-bM IR has yet to be released. But if this follows the Draft Opinion, there will be a formal requirement for the EIR and C-bM IR courses to be approved, in common with all other courses for Part-FCL licences, ratings and certificates, even though freelance instructors may teach part of these courses.

As they will have to pay the CAA for course approval, it will be interesting to note how ATOs propose to manage the use of 'freelance' instructors for part of their courses, rather than using their own IRIs.

bose-x, does your ATO intend to provide EIR and C-bM IR courses and to accept that part of the training may be conducted by freelance IRIs?

[S-Works]

We will be offering the EIR and CBM in due course.

It is not planned for us to use any freelance IRIs. We have our own guys on staff who have to earn a living. They do this from our approvals which cost a huge amount of money to maintain and I can't see the company allowing a freelancer to gain the benefit of that time and expense while the internal guys sit idle.

Whilst the concept of a freelancer teaching for these ratings is laudable, the requirement for the courses to be approved as beagle points out means they will still need to be completed in an ATO. The cost of gaining approvals is likely to kill the freelance Instructors pretty much dead I suspect.

[BEagle]

There's also the not inconsiderable issue of ensuring that 'freelance' instructors are standardised within the ATO's training manual SOPs to consider.....

I wonder from whence EASA considers that all the IREs required to support the C-bM IR and EIR will come?

[justmaybe]

Quote:
"The cost of gaining approvals is likely to kill the freelance Instructors pretty much dead I suspect".
I think the costs, which are unlikely to decrease, may well have a terminal effect on small schools and clubs as well.

[S-Works]

The standardisation is going to be an interesting issue. Our students are taught by the same team and generally the same Instructor where possible throughout a course. All of them are standardised by me and teach the same content in the same way in accordance with our approvals.

A freelancer is going to teach how they see fit and then throw them over the wall so to speak into an ATO where the change of pace is very likely to be an issue for the student in terms of adapting to different process and methods. I can see this leading to a considerable increase in training time for the student to adapt which of course will be blamed on the ATO not the free lancer.

The other issue I suspect is that we do a considerable amount of training in an FNPTII, this allows the student to practice what if scenarios and re run at the click of a mouse areas that are pooched up. A freelancer is not going to have access to this which will mean a lot of training done in the aircraft and a real increase in the cost of obtaining an IR. Our sim is half the price of the aircraft.

[S-Works]

I think the costs, which are unlikely to decrease, may well have a terminal effect on small schools and clubs as well.

I think it depends on the type of school. Certainly small RTF's who have not experienced the full force of the controlled environment are going to struggle. FTO's and TRTO that have transitioned to ATO fully are not seeing an issue. If anything our costs have actually gone down in transitioning to an ATO as we were previously and RTF, FTO and TRTO. Now as a single entity we only pay one set of fees.

[BEagle]

bose-x wrote: A freelancer is going to teach how they see fit and then throw them over the wall so to speak into an ATO where the change of pace is very likely to be an issue for the student in terms of adapting to different process and methods.

That would clearly be an undesirable situation. However, if the freelance instructor is 'associated with' a specific ATO and suitably standardised, it would be less of a problem. Except for the standardisation costs, of course - and the perception by an ATO's resident instructors that a freelance instructor is taking the bread from their mouths.... Which would require careful management.

But it could suit an ATO to use a nominated freelance instructor for certain specific elements of the course, particularly if the course is for a student using his/her own aeroplane, perhaps?

[S-Works]

I have no doubt that there will be a few schools that may consider it or even benefit from it. For us it's unlikely as we have full and part timers that get the priority.

Keeping externals standardised is cost and effort that I can't really justify.

[Level Attitude]

That would clearly be an undesirable situation. However, if the freelance instructor is 'associated with' a specific ATO and suitably standardised, it would be less of a problem. Except for the standardisation costs, of course - and the perception by an ATO's resident instructors that a freelance instructor is taking the bread from their mouths.... Which would require careful management.I think this sentiment is the opposite of what should be expressed - and
goes against the reason for the CB IR and (possibly) the EIR in the first
place.

Independent Instructors should be welcomed as a source of potential new
students for ATOs - not seen as a threat to existing work of ATO Instructors.

Although the result of any flight training should be to produce safe,
competent pilots - The actual aim of any training (what a student is
paying for) is for the student to obtain Test Standard flying - which
does not have to be only by fully standardised training.

Keeping externals standardised is cost and effort that I can't really justify.You shouldn't have to. For any student wanting to claim prior IFR instruction
an Instructor Report is required, along with a flight test by the ATO to
assess competency.

If student is competent, but does things slightly differently to your
course - it shouldn't matter.

An ATO will need Course Approval for CB IR and EIR.
As part of that just put in a line saying that students joining a course
with prior IFR training are not required to amend their methods provided
an equivalent level of safety and competence is demonstrated and maintained.

[BEagle]

Level Attitude wrote:An ATO will need Course Approval for CB IR and EIR.

As part of that just put in a line saying that students joining a course with prior IFR training are not required to amend their methods provided an equivalent level of safety and competence is demonstrated and maintained

Oh I can really see an ATO doing that.....:rolleyes:

[Whopity]

there will be a formal requirement for the EIR and C-bM IR courses to be approved, in common with all other courses for Part-FCL licences, ratings and certificates, even though freelance instructors may teach part of these courses.If we look at the original NPAWhen the applicant has: - completed instrument flight instruction under the supervision of an IRI(A) or an FI(A) holding the privilege to provide training for the IR; or - prior experience of flight time by reference to instruments as PIC on aeroplanes, under a rating giving the privileges to fly under IFR or in IMC, these hours may be counted towards the 40 hours above up to a maximum of 30 hours. Then it says:In any case, the flight instruction part of the training course shall include at least 10 hours of dual instrument flight instruction in an aeroplane at an ATO So I fail to see what connection the frelance FI/IRI has to do with the ATO!

[BEagle]

Whopity, the point being made is that, if an ATO is content to accept the maximum 30 hrs training from one or more 'non-associated' freelance, non-standardised instructors, it might well be far more difficult to prepare the student for the Skill Test in 10 hrs than if the training had been delivered by the ATOs 'all singing from the same hymn book' instructors.

The ATO would also need to convince the Authority that it had a sound process for managing such a situation.

However, if the freelance instructor is associated with the ATO to such an extent that he/she is fully conversant with their SOPs etc., the problem is rather less.

[Whopity]

As the training for the IMC (IR(R)) will count towards that 30 hours, I'd be vary wary of shooting onesself in the foot!

[Timothy]

I note that nearly all of this discussion is framed in terms of the needs of ATOs and their staff instructors rather than the needs of the students.

Is it just possible that there is a connection between that attitude and the reason why some students like to work with an Independent?

Only asking ;)

[Mickey Kaye]

Sad isn't it.

But then when you are paying 10 grand for your sim to be approved and god knows what in time and money in writing and getting manuals approved its no surprise really.

[nick14]

LA

I'm afraid I have to disagree with you statement regarding the aim of training. It should not be training to pass the test, it should be training to safely operate the aircraft at the appropriate level. At which point a student will be able to pass the test however the end goal is not the pass.

[Timothy]

What students pay me for is to keep them and their families as safe as possible in years to come.

They are more than willing to pay for more long briefs, which go way beyond the syllabus, and more training time, to achieve that.

Passing the skills test is a step on the road.

Having said that, there are far more students out there who want to get their IMCR or IR in the statutory minimum time and hours. That's fine, but the result will be different.

It's horses for courses and isn't great that people have the choice?

[belowradar]

The customer is king and in this new EASA world the customer can do the bulk of IR training with an independent instructor (and why not?)

Previous IFR flight experience will count count and can be credited so the smart ATO's will work with freelancers to ensure that the customer gets the appropriate standard of training. ;)

[S-Works]

Or the ATOs will close ranks and not accept training from free lance instructors against their approvals. It may be that the customer is king, but without an ATO the previous training is worth squat if the ATO does not want to accept it.

Despite the fact that I would standardise Timothy in a heart beat and accept his training, there are not many independent instructors that I would be prepared to do this with.

*** I make the point that Timothy is a friend who I have known for several years and have examined and consider to be an excellent pilot not just from his internet posts.....

[Timothy]

Bose,

I have been "validated" by a number of ATOs, and am delighted that you would accept my training as well, so the next point isn't about me or you.

...and that point is that if someone has 30 hours of independent instruction and presents themselves to an ATO that won't accept them, there will always be another ATO across the road, or across the water, that will.

It is also hoped that the number of CBM-IR and EIR approved ATOs will be far greater than the JAR IR ones, giving the student more local choice.

But only time will tell.

[S-Works]

I can't see many new ATOs springing up to offer the new flavours of IR. My guess is that it will be the existing ATOs that add the approval as the cost of setting a new ATO is just eye watering and in what is a dwindling market is probably not cost effective. This is apparent from the number of RTF calling it a day because they can't manage the transition just from RTF to ATO.

Therefore I would say that any prospective candidate wanting to go to an ATO and have the training by an unknown accepted ensure up front the ATO will accept it. I can't see many doing so for the reasons mentioned earlier.

But as you say, only time will tell.

[Timothy]

The whole point is to stop the market dwindling.

I have been talking at Friedrichshafen about this for some years, and the interest in Europe is huge. I hope and believe that this will be the next big thing, and I think that ATOs who think that it will be business as usual will miss out big time.

[belowradar]

I'm with Timothy on this one sorry Bosex

If a prospective client presents him or herself with previouse IFR hours and experience logged by a suitably qualified IRI are you seriously going to screw them around just because you want to buck the system that has been put in place, they will soon realise who the old school monopy ATOs are and spend their money with more enlightened ones.

Let's face it an IRI is not something that is given away to anyone

[S-Works]

I am all for anything that helps boost the industry. However I remain doubtful about the reality.

[Duchess_Driver]

Surely the aim of this is that provided...

A) the student has the required minimum training, and
B) meets ten required standards on the AOC/Test

there can be no argument from the authority as to issuing the rating.

From my point of view, yes I'd like everybody to work in a standardised manner, but in reality so long as the student observes my SOPs and training manual standards for the 10hours he's with me then I don't care what went before - so long as it's all documented and ship shape:eek: and that may be the problem here, merging 3,4 or 5 sets of training administration into one comprehensive document.

[Level Attitude]

Surely the aim of this is that .......
A) the student has the required minimum training, and
B) meets the required standards on the AOC/TestTotally Agree !

- 2 Modules of modular IR = min 50 Hours IF
- Full CB IR = min 40 Hours IF

Not a huge difference in minimum training required - will attract some, but
probably not many, additional IR students as compared to now.

- CB IR (with 30 Hours previous IFR Experience) = Pre-entry assessment
flight plus min 10 Hours IF.

This will bring many, many additional paying customers to CB-IR ATOs.

As Test Standard must be met, I personally doubt many candidates would
complete in minimum anyway.

ATOs who will only offer "Full" CB IR courses are doing the aviation
community a disservice and are excluding themselves from a, potentially,
very lucrative additional revenue stream.